EUDR implementation briefing
- EUDR compliance begins in December 2026 for larger companies
- Further EUDR simplifications appear unlikely despite continued political opposition
- Industry support remains strong, though some companies seek changes
- A third delay remains possible but implementation appears more likely
- Further delays could undermine EUDR and EU credibility
The European Union Deforestation Regulation (EUDR) is on the horizon.
The deadline is fast approaching: larger companies will need to comply with the law from 30 December 2026, with the deadline for smaller companies coming six months later on 30 June 2027.
The law has seen two delays and several simplifications since it was first proposed.
Now that we’re on the home stretch, what are the chances that the landmark law will see last-minute changes, alterations or delays? Will it get over the line as planned?
The state of the EUDR
The EUDR has been through many shifts. In 2024, the regulation was delayed, which was followed in 2025 by a second year-long delay. Then, earlier this year, a simplification package was released, easing compliance burdens for certain operators.
Yet in the view of Bill Cordingley, barrister at the law firm Browne Jacobson, we have now arrived at the “definitive version” of the EUDR, or at least close to it.
“The Commission has already implemented a substantial simplification exercise and argues that, as a result, compliance costs have been significantly reduced.”
If there are any further changes, he suggests, they are more likely to focus on practical implementation issues, guidance and administrative burdens, rather than reworking the traceability and due diligence requirements themselves.
Further simplifications are “unlikely”, suggests Nicole Polsterer, sustainable consumption and production campaigner at the NGO Fern. Fern is not aware of a sizeable group within the European Parliament pushing for more simplifications.
Opposition to the EUDR from industry
The industry is broadly supportive of the EUDR, with companies such as Barry Callebaut and Ferrero showing strong support.
However, opposition has been voiced from some quarters, with snacking giant Mondelēz International and coffee company Lavazza traditionally pushing for simplifications.
According to NGO Global Witness, Mondelēz has been lobbying the US government, with CEO Dirk Van de Put meeting US Ambassador to the EU Andrew Puzder to push to weaken the law.
According to Global Witness, Mondelēz has also been executing a “pan-European lobbying strategy”, targeting conservative MEPs in Brussels as well as meeting with governments in France, Germany, Ireland and Luxembourg.
In response to Global Witness’s piece, a Mondelēz spokesperson said that the company “fully supports the objectives of the EU Deforestation Regulation and remains committed to deforestation-free supply chains and responsible sourcing across our operations and value chain”.
Opposition to the EUDR from governments
The EUDR also faces opposition from the US, with Puzder describing it as “textbook overregulation”, which will “impose significant regulatory compliance costs while producing inconsequential environmental benefit”.
The US has asked for further simplifications for low-risk countries, explains Fern’s Polsterer.
Yet Cordingley does not believe that, at this stage, opposition from the US could lead to further changes. On the one hand, “external political pressures could still have some influence on the debate”, and concerns from trading partners such as the US could reinforce existing trends towards deregulation and attempts to rejuvenate competitiveness.
On the other, “the EUDR remains one of the EU’s flagship environmental measures and is not far off coming into force and so I do not think pressure from climate-sceptical governments alone is likely to be enough to derail it altogether”.
Opposition to the EUDR from the European Parliament
Then there is opposition from within the European Parliament. Groups such as the centre-right European People’s Party (EPP) have long been in favour of simplifications and revisions to the EUDR.
“Internally we know there is now a sizeable political constituency within the Parliament that would weaken parts of the regulation given the opportunity,” says Cordingley.
Yet a substantial coalition of MEPs still back the regulation and oppose any significant rollback. While Cordingley sees the potential for some pressure to further moderate the rules, he does not believe that there is an obvious Parliamentary majority to dismantle the regime entirely.
Could there be a third delay?
It would be “foolish” to rule out the possibility of a third delay, says Cordingley. EU Member States are still lobbying for further simplification and postponement. Political resistance has far from disappeared.
At the same time, the European Commission has presented the simplification package as addressing the concerns of industry and Member States, he says. It has repeatedly stressed the current timetable.
“I think implementation in December 2026 remains more likely than another delay but I can’t fully discount the political picture shifting quickly in the weeks ahead.”
How could further simplifications impact the law?
If more changes were introduced to the law, it would significantly weaken its credibility, suggests Tina Schneider, director of forest governance and policy at the organisation World Resources Institute (WRI).
“Moving the goalposts again would undermine confidence in the regulatory process and raise serious questions about the EU’s commitment to delivering on the environmental goals the law was designed to achieve.”
A third delay would weaken the credibility not only of the EUDR but of the EU itself, suggests Fern’s Polsterer. She suggests that if there is a delay, it may be blamed on the IT system or on food security.
Right now, things are looking good for the EUDR. But in the past, events have moved quickly. While opposition to the regulation remains, further simplifications, or even a further delay, cannot be completely ruled out.
